Maintain before-and-after technical and purpose records: What evidence best resolves substantial-modification
Responsibility requires comparative evidence linking technical changes and changed intended purpose to the resulting system and actor.
The question
In an EU education administration department, assume relevant EU AI Act duties apply. A vendor supplies a student-support model, and the department retrains it on local records, adds automated eligibility recommendations, and changes the stated purpose from assistance to admissions screening. What evidence best resolves substantial-modification responsibility?
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- Compare the original and modified intended purposes.Purpose comparison is necessary, but alone it does not establish the technical changes, resulting functions, or the actor responsible for them.
- Record the department’s approval date.An approval date establishes timing but does not show what changed, whether the intended purpose changed, or which actor made the relevant intervention.
- Obtain a post-deployment conformity assessment covering the final system.A later assessment may address conformity, but it does not by itself document the modification’s scope, timing, or responsibility.
- Maintain before-and-after technical and purpose records. ✓Comparative records connect retraining, added recommendations, the changed purpose, resulting functions, and the responsible actor.
The trap
Build a dated before-and-after record connecting each technical or purpose change to the resulting system and actor. How to remember it
Responsibility requires comparative evidence linking technical changes and changed intended purpose to the resulting system and actor.
How many of these would you get right?
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